Loiola v. O'Malley

CourtDistrict Court, S.D. New York
DecidedMarch 24, 2025
Docket1:24-cv-05155
StatusUnknown

This text of Loiola v. O'Malley (Loiola v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Loiola v. O'Malley, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------- NICHOLAS L.,

Plaintiff, DECISION AND ORDER 1:24-cv-05155-GRJ v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. ----------------------------------------------------- GARY R. JONES, United States Magistrate Judge:

In November of 2021, Plaintiff Nicholas L.1 applied for Disability Insurance Benefits under the Social Security Act. The Commissioner of Social Security denied the application. Plaintiff, represented by Lewis Bart Insler, Esq., of counsel, commenced this action seeking judicial review of the Commissioner’s denial of benefits under 42 U.S.C. §§ 405 (g) and 1383 (c)(3). The parties consented to the jurisdiction of a United States Magistrate Judge. (Docket No. 11). This case was referred to the undersigned on March 17, 2025. Presently pending is Plaintiff’s Motion for Judgment on the Pleadings pursuant to Rule 12 (c) of the Federal Rules of Civil Procedure. (Docket

1 Plaintiff’s name has been partially redacted in compliance with Federal Rule of Civil Procedure 5.2 (c)(2)(B) and the recommendation of the Committee on Court Administration and Case Management of the Judicial Conference of the United States. No. 17). For the following reasons, Plaintiff’s motion is due to be granted, and this matter is remanded for further administrative proceedings.

I. BACKGROUND A. Administrative Proceedings Plaintiff applied for benefits on November 15, 2021, alleging disability

beginning January 1, 2018. (T at 215-16).2 Plaintiff’s application was denied initially and on reconsideration. He requested a hearing before an Administrative Law Judge (“ALJ”). A hearing was held on July 18, 2023, before ALJ Michael Stacchini. (T at 36-68). Plaintiff appeared with an

attorney and testified. (T at 42-58). The ALJ also received testimony from Esperanza Distefano, a vocational expert. (T at 58-67). B. ALJ’s Decision

On July 28, 2023, ALJ Stacchini issued a decision denying the application for benefits. (T at 15-35). The ALJ found that Plaintiff met the insured status requirements of the Social Security Act through December 31, 2022 (the date last insured). (T at 20). The ALJ determined that

Plaintiff did not engage in substantial gainful activity between January 1, 2018 (the alleged onset date) and the date last insured. (T at 20).

2 Citations to “T” refer to the administrative record transcript at Docket No. 12. The ALJ concluded that, as of the date last insured, Plaintiff’s degenerative disc disease of the lumbar and cervical spine, insomnia,

depressive disorder, anxiety disorder, and panic disorder were severe impairments as defined under the Act. (T at 20). However, the ALJ found that, as of the date last insured, Plaintiff did

not have an impairment or combination of impairments that met or medically equaled one of the listed impairments in 20 CFR Part 403, Subpart P, Appendix 1. (T at 21). At step four of the sequential analysis the ALJ determined that, as of

the date last insured, Plaintiff retained the residual functional capacity (“RFC”) to perform light work, as defined in 20 CFR 404.1567 (b), with the following limitations: he could sit, stand and walk for 6 hours in an 8 hour

workday with regularly scheduled breaks, but was unable to climb ladders, ropes or scaffolds and could only occasionally climb ramps and stairs. (T at 23). Plaintiff could occasionally balance, stoop, kneel, crouch and crawl, but must avoid unprotected heights and hazardous machinery. (T at 23).

The ALJ further found that, as of the date last insured, Plaintiff could understand, remember, and carry out simple routine tasks with regular breaks at approximately 2-hour intervals with decision-making and changes

in a work setting requiring only simple, routine, and repetitive tasks. (T at 23). In addition, he could handle brief and superficial interaction with the public and occasional interaction with supervisors and coworkers, but

without tandem tasks. (T at 23). The ALJ concluded that, as of the date last insured, Plaintiff could not perform his past relevant work as a carpenter. (T at 28). However,

considering Plaintiff’s age (43 on the date last insured), education (at least high school), work experience, and RFC, the ALJ determined that there were jobs that existed in significant numbers in the national economy that Plaintiff could have performed as of the date last insured. (T at 28).

As such, the ALJ found that Plaintiff had not been under a disability, as defined under the Social Security Act, and was not entitled to benefits for the period between the alleged onset date and the date last insured. (T

at 29). On May 6, 2024, the Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the Commissioner’s final decision. (T at 1-7). C. Procedural History Plaintiff commenced this action, by and through his counsel, by filing

a Complaint on July 8, 2024. (Docket No. 1). On October 18, 2024, Plaintiff filed a motion for judgment on the pleadings, supported by a memorandum of law. (Docket Nos. 17, 18). The Commissioner interposed a brief on

January 14, 2025, opposing the motion and requesting judgment on the pleadings. (Docket No. 20). On January 21, 2025, Plaintiff submitted a reply memorandum of law in further support of his motion. (Docket No. 21). II.APPLICABLE LAW

A. Standard of Review “It is not the function of a reviewing court to decide de novo whether a claimant was disabled.” Melville v. Apfel, 198 F.3d 45, 52 (2d Cir. 1999).

The court’s review is limited to “determin[ing] whether there is substantial evidence supporting the Commissioner's decision and whether the Commissioner applied the correct legal standard.” Poupore v. Astrue, 566 F.3d 303, 305 (2d Cir. 2009) (per curiam).

The reviewing court defers to the Commissioner's factual findings, which are considered conclusive if supported by substantial evidence. See 42 U.S.C. § 405(g). “Substantial evidence” is “more than a mere scintilla”

and “means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Lamay v. Commissioner of Soc. Sec., 562 F.3d 503, 507 (2d Cir. 2009) (internal quotations omitted) (quoting

Richardson v. Perales, 402 U.S. 389, 401 (1971)). “In determining whether the agency's findings are supported by substantial evidence, the reviewing court is required to examine the entire

record, including contradictory evidence and evidence from which conflicting inferences can be drawn.” Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012) (internal quotations omitted). “When there are gaps in the administrative record or the ALJ has

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Talavera v. Comm’r of Social Security
697 F.3d 145 (Second Circuit, 2012)
Sims v. Apfel
530 U.S. 103 (Supreme Court, 2000)
Lamay v. Commissioner of Social SEC.
562 F.3d 503 (Second Circuit, 2009)
Poupore v. Astrue
566 F.3d 303 (Second Circuit, 2009)
Peed v. Sullivan
778 F. Supp. 1241 (E.D. New York, 1991)
Batista v. Barnhart
326 F. Supp. 2d 345 (E.D. New York, 2004)
Piscope v. Colvin
201 F. Supp. 3d 456 (S.D. New York, 2016)
Marinez v. Commissioner of Social Security
269 F. Supp. 3d 207 (S.D. New York, 2017)
Rolon v. Commissioner of Social Security
994 F. Supp. 2d 496 (S.D. New York, 2014)

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